Third-Party Ethical Standards • ib vogt

Group Third-Party Ethical Standards

1 Aim and Scope

At ib vogt, we are committed to building a future where sustainable energy solutions are the norm and where every aspect of our business operations reflects our core values of integrity, responsibility, and innovation. As a global player in the renewable energy sector, we recognise that our Suppliers are crucial in helping us achieve these goals. Together, we can drive meaningful change, promote sustainability, and ensure that our business practices meet the highest ethical standards.

This Global Third-Party Ethical Standards (hereinafter referred to as “Standards”) outline our expectations for all suppliers, vendors, contractors, service providers, consultants, and business partners (collectively referred to as “Suppliers”) who work with or on behalf of ib vogt GmbH and/or subsidiaries, affiliates, and businesses under ib vogt’s direct or indirect management control (hereinafter referred to as “ib vogt”). These Standards are designed to ensure that our supply chain operates in a manner consistent with our commitment to environmental stewardship, human rights, ethical business conduct, and social responsibility.

Adherence to the Standards is mandatory for all Suppliers, and compliance will be monitored regularly. ib vogt reserves the right to suspend or terminate relationships with any Suppliers that fails to comply with the Standard or applicable laws.

These Standards do not extend to Suppliers engaged in providing professional services such as legal, insurance, financial, accounting and tax-related advisory services.

These Standards are intended to apply in all countries where ib vogt operates. If local laws, rules, or regulations provide a higher level of protection than what is contained in these Standards, local legislation shall prevail.

These Standards also extend to any subcontractors our Suppliers might engage. Our Suppliers are responsible for ensuring their subcontractors comply with our Standards.

2 Objectives

These Standards reflect our shared commitment, and every Supplier of ib vogt is expected to fulfil its obligations in accordance with these Standards.

What do we expect from our Suppliers?

Conduct with Integrity
Suppliers should conduct business ethically and comply with all applicable laws.

Compliance with Stricter Regulations
If local laws or regulations are stricter than these Standards, Suppliers are expected to adhere to those higher requirements.

Implementation of Standards
Suppliers shall implement the principles laid out in these Standards and ensure that they are practiced throughout their supply chain, including subcontractors and other agents or other representatives who perform work on their behalf.

Avoidance of Impropriety
Suppliers should avoid any activities that could even create the appearance of impropriety.

3 Human Rights and Labor Standards

At ib vogt, we believe that respect for human rights is non-negotiable. We expect our Suppliers to adhere strictly to international labour practices and human rights standards. This includes a firm commitment to prohibiting forced labour and human trafficking in all forms. All work should be voluntary, and workers should be free to leave employment without fear of coercion or threats. Suppliers shall fully comply with all applicable human rights and labour laws, actively supporting the protection of universally recognised human rights and ensuring they are not complicit in any human rights violations.

The use of child labour and forced labour is strictly prohibited. Suppliers should prevent all forms of forced or compulsory labour and strictly prohibit any form of child labour. Suppliers should comply with the minimum age requirements stipulated by local laws and international conventions. Suppliers should adopt procedures to verify and maintain documentation that workers have reached the age for completing compulsory education and the minimum age for employment in the country.

Additionally, we expect our Suppliers to support workers’ rights to freely associate and engage in collective bargaining. This includes respecting the formation and functioning of trade unions and ensuring that all workers are treated with dignity and fairness, receiving fair wages, reasonable working hours, and all legally mandated benefits.

Suppliers are committed to fostering a work environment free from discrimination and respecting all individuals’ dignity, privacy, and rights. They shall promote equal treatment regardless of gender, age, ethnicity, nationality, disability, sexual orientation, union membership, social background, or political and religious beliefs. Special attention should be given to the protection of vulnerable groups, including migrant workers and minorities, to ensure they are not subjected to unfair treatment.

Suppliers shall adhere to the principles of International Labour Standards as established by the International Labour Organisation.

Suppliers should comply with regulations that ensure fair working conditions, allowing employees to raise concerns openly and without fear of retaliation.

4 Environmental and Social Responsibility

Environmental responsibility is at the heart of ib vogt’s operations, and we expect our Suppliers to share in this commitment. Suppliers should actively work to reduce their environmental footprint by striving for net-zero greenhouse gas emissions, in line with the goals of the Paris Agreement. This involves adopting energy-efficient practices, utilising renewable energy sources, and continuously seeking ways to improve energy management.

Suppliers should ensure that raw materials are sourced responsibly, avoid contributing to deforestation, and ensure that land use practices are sustainable. Continuous environmental improvement should be a priority, with Suppliers regularly reviewing and enhancing their environmental performance to meet or exceed regulatory and industry standards.

We expect our Suppliers to share this commitment by aligning their practices with global sustainability frameworks, such as the UN Global Compact and the Sustainable Development Goals (SDGs). This includes taking active steps to reduce carbon footprints, conserve natural resources, and promote social equity.

Suppliers shall comply with applicable environmental protection regulations. The use of energy-efficient technologies and adopting an adequate environmental management system.

Engagement with local communities is another important aspect of social responsibility. Suppliers should actively participate in community development initiatives and ensure their operations do not negatively impact local populations. This includes respecting land rights and ensuring all land acquisitions are conducted ethically and transparently.

Suppliers should also foster diversity and inclusion within their operations and supply chains. This not only supports social justice but also drives innovation and business success. By embracing diverse perspectives and ensuring equitable opportunities, Suppliers can contribute to a more inclusive global economy.

5 Ethical business practices and compliance with the law

Ethical behaviour is fundamental to how we do business at ib vogt. We require our Suppliers to conduct their operations with the highest levels of integrity.

In addition, Suppliers should maintain an environment where employees can report unethical behaviour or violations of these standards without fear of retaliation. Whistleblower protections should be in place, ensuring that grievances are handled fairly and confidentially.

Compliance with all applicable laws and regulations is fundamental to our business operations. We expect our Suppliers to be knowledgeable about and adhere to all relevant legal requirements, including those specific to their industry and geographic location.

Suppliers should ensure that they obtain and maintain all necessary permits, licenses, and certifications, and that they meet all legal reporting obligations. In cases where local laws are less stringent than these Standards, Suppliers are expected to follow the higher standard.

When legal discrepancies arise, Suppliers should address them proactively and transparently. Open communication with ib vogt regarding legal compliance issues is essential to maintaining trust and ensuring that all operations are conducted lawfully and ethically

5.1 Conflict of Interest

Suppliers are expected to proactively and transparently manage conflicts of interest, disclosing any situations that could influence their judgment or objectivity.

Suppliers shall avoid conflicts of interest arising from secondary employment and equity investments.

Suppliers are expected to disclose to us any situation that may appear as a conflict of interest and disclose to ib vogt if any ib vogt employee or anyone under contract with ib vogt may have an interest in the Suppliers’ business or any economic ties with the Suppliers.

Protecting ib vogt’s proprietary information and intellectual property is another critical expectation. Suppliers should ensure that all confidential information is safeguarded and used only as authorised.

5.2 Combat bribery and corruption

Ethical behaviour is fundamental to how we do business at ib vogt. We require our Suppliers to conduct their operations with the highest levels of integrity, rejecting all forms of corruption and bribery. Compliance with international anti-corruption laws, such as the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, is mandatory. Suppliers should implement strong anti-corruption policies and ensure that all business dealings are conducted transparently and ethically.

ib vogt maintains a zero-tolerance policy toward bribery and corruption. Suppliers should have systems in place to prevent, detect, investigate, and respond to allegations or incidents of corruption and bribery.

5.3 Combat Money Laundering

Suppliers shall comply with all laws and regulations relating to anti-money laundering and combating the financing of terrorist activities. ib vogt maintains a zero-tolerance policy toward money laundering and the financing of terrorism.

5.4 Fair trade and free markets

Suppliers shall refrain from engaging in any collusive practices that violate competition or antitrust laws. Suppliers shall comply with national and international laws governing the import, export, and domestic trade of goods, technologies, or services and the handling of specific products and financial transactions. Suppliers shall ensure compliance with all export control and customs regulations and implement appropriate measures to ensure that transactions with third parties do not breach applicable economic embargoes, trade regulations, import and export controls, or laws aimed at combating the financing of terrorism.

5.5 Intellectual property, Data Protection and Information Security

Data protection is paramount in an increasingly digital world. Suppliers should ensure the confidentiality, integrity, and security of all data they handle, particularly sensitive and personal information. Compliance with relevant data protection laws, such as the General Data Protection Regulation (GDPR), is non-negotiable.

Suppliers shall take all necessary measures to protect information and IT systems and implement appropriate safeguards to protect against data breaches, cyberattacks, and other threats to digital infrastructure. This includes regular monitoring, risk assessments, and incident management procedures to quickly address any potential vulnerabilities.

Data integrity is equally important. Suppliers should ensure that all data is accurate, complete, and reliable, supporting effective decision-making and maintaining trust across all business interactions.

5.6 Health, Occupational Safety and well-being

Suppliers are required to comply with all relevant health and safety regulations, securing and maintaining any necessary permits, licenses, and registrations. It is imperative always to ensure a safe and healthy work environment. ib vogt highly recommends that our Suppliers implement a safety management system in alignment with ISO 45001 standards (or equivalent).

Policy and Procedure Compliance
Suppliers are expected to establish comprehensive policies and procedures that ensure adherence to all applicable safety, health, and environmental laws. This includes compliance with international and local laws regarding material sourcing, transport, storage, manufacturing processes, and waste disposal, including hazardous materials, air emissions, discharges, and toxic substances.

Hazard Identification and Mitigation
Suppliers should identify, evaluate, and eliminate or mitigate workers’ exposure to harmful chemical, biological, and physical agents. If hazard elimination is not feasible, appropriate controls such as closed systems and ventilation should be implemented. Suppliers should strive to eliminate or substantially control hazards, establish safe work procedures, and provide suitable personal protective equipment (PPE).

Emergency Preparedness
Suppliers are expected to identify and assess potential emergency situations and minimise their impact through the development of emergency plans and response procedures. This includes worker notification and evacuation protocols, worker training and drills, proper fire detection and suppression systems, adequate exit facilities, and first aid supplies.

Occupational Injury and Illness Management
Suppliers should maintain procedures and systems to manage, track, investigate, and report occupational injuries and illnesses promptly, ensuring continuous improvement in workplace safety.

Workplace Safety Information and Training
Suppliers are expected to offer comprehensive workplace health and safety information, training, and warnings in the workers’ primary language. Safety Data Sheets (SDS) for hazardous or toxic substances should be clearly posted in the workplace. Efforts should be made to eliminate physical hazards, establish effective training and safe work procedures, and provide and maintain appropriate PPE, including physical guards, interlocks, and barriers. Workers should be informed about safety protocols and feel empowered to report unsafe conditions or practices without fear of retaliation. Any workplace incidents should be promptly reported and addressed to prevent future occurrences.
Suppliers are expected to offer comprehensive workplace health and safety information, training, and warnings in the workers’ primary language. Safety Data Sheets (SDS) for hazardous or toxic substances should be clearly posted in the workplace. Efforts should be made to eliminate physical hazards, establish effective training and safe work procedures, and provide and maintain appropriate PPE, including physical guards, interlocks, and barriers. Workers should be informed about safety protocols and feel empowered to report unsafe conditions or practices without fear of retaliation. Any workplace incidents should be promptly reported and addressed to prevent future occurrences.

6 Financial Integrity

All financial books and records should conform to generally accepted accounting principles. Supplier records should be accurate in all material respects: (i) records should be legible, transparent, and reflect actual transactions and payments. (i) Do not hide, fail to record, or make false entries.

7 Product Quality

At ib vogt, we are committed to delivering products and services that meet the highest quality and safety standards. We expect our Suppliers to uphold these same standards by complying with internationally recognised quality management systems. This ensures that all products and services provided meet or exceed the expectations of ib vogt and its customers.

Continuous improvement is key to maintaining high-quality standards. Suppliers should regularly review their processes and products to identify opportunities for enhancement. This commitment to excellence helps to ensure that all products are safe, reliable, and compliant with relevant regulations.

Transparency in the supply chain is also critical. Suppliers should ensure that their supply chains are traceable and that all materials and components used in production are sourced responsibly. This helps to maintain the integrity of our products and supports our commitment to ethical and sustainable business practices.

8 Governance, Compliance, and Risk Management

Strong governance practices are essential for maintaining trust and ensuring that all parties meet their obligations. Suppliers should establish and maintain compliance management systems that ensure adherence to all applicable laws and these Standards. These systems should include regular trainings, audits and assessments to verify compliance and identify areas for improvement.

Proactive risk management is also crucial. Suppliers should implement strategies to identify, assess, and mitigate risks, particularly those related to environmental, social, and governance (ESG) factors. Clear accountability structures should be in place to ensure that non-compliance is addressed swiftly and transparently.

Suppliers are encouraged to maintain open communication with ib vogt regarding their compliance efforts and any challenges they may face. By fostering a culture of continuous improvement, we can work together to address potential risks and ensure that all operations align with our shared values.

9 Right of audit

To ensure that these Standards are met, ib vogt reserves the right to conduct regular audits and assessments. These may be carried out by ib vogt or by third-party auditors. Suppliers are expected to cooperate fully with these audits and to provide all necessary documentation and access.

In cases of non-compliance, ib vogt will work with Suppliers to address the issues and implement corrective actions. However, repeated or severe violations may result in the termination of the business relationship.

Suppliers are also expected to establish grievance mechanisms that allow employees and other stakeholders to report concerns or violations of these Standards confidentially and without fear of retaliation. ib vogt is committed to fostering a culture of accountability and transparency, ensuring that any violations are promptly addressed and rectified.

10 Report a Potential Violation or Other Concern

Every Supplier has the right and the duty to report actual and potential violations of these Standards. Raise your concerns, regardless of whether they directly affect you or your business area. You can report concerns via the Smart Integrity Platform here.

Reporting can be done anonymously were permitted by law. Translation services are also available. ib vogt strictly prohibits intimidation or retaliation against a person who reports questionable ethical conduct in good faith, provides information, and/or otherwise assists in an investigation, and/or files, testifies, participates in, or otherwise assists in any related proceedings of matters brought to the attention of ib vogt.

If, despite the prohibition, there are measures against the whistleblower that could be defined as retaliation, these should be reported immediately via the Smart Integrity Platform. All reports of retaliation shall be investigated confidentially.

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